Daniel A. Leipold
- SB #77159
Cathy L. Shipe - SB #156453
LEIPOLD, DONOHUE & SHIPE, LLP
160-A West Seventeenth Street
Santa Ana, CA 92706
Telephone: (714) 796-1555
HUB LAW OFFICES
711 Sir Francis Drake Bivd.
San Anselmo, CA 94960
PAUL LOPEZ, by and through his Guardian ad Litem
COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT
RAUL LOPEZ, by and through his Guardian ad Litem, ALICIA LOPEZ,
CHURCH OF SCIENTOLOGY MISSION OF BUENAVENTURA, CELEBRITY CENTRE INTERNATIONAL, CHURCH OF SCIENTOLOGY FLAG LAND BASE, WORLD INSTITUTE OF SCIENTOLOGY ENTERPRISES, CHURCH OF SCIENTOLOGY RELIGIOUS TRUST, ROBERT CEFAIL, TOLI CEFAIL, MICHAEL ZETNER, THE RC&A, GROUP, INC., MICHAEL HALEY, BRENT JONES, RAUL VALLE, TOM STEINER and DOES 2 through 50, inclusive,
CASE NO.: BC200852
JUDGE REGINALD A. DUNN,
DECLARATION OF JESSE PRINCE
I, Jesse Prince declare as follows;
1 . I am over 18
years of age and currently reside in the State of Colorado, County of
Boulder. This declaration is of my own personal knowledge and if called
upon to testify to the facts herein I could and would be competently able
to testify thereto.
2 . I am intimately familiar with the Scientology organization, movement and beliefs because I was in scientology for 16 years (1976-92) and served in the lighest ranks, including as the second in command of the Religious Technology Center (RTC). At that time, my position was "Deputy Inspector General, External" which meant being in charge of all activities outside the body of Scientology. This included being in charge of all litigation by or against any Scientology organization, intelligence (spying, covert operations) brought against perceived or imagined "enemies" (which ranged from critics to media to the courts), trademark registrations, and the licensing of trademarks to other Scientology organizations, which was how we tightly controlled all Scientology corporations while creating the false impression of "corporate integrity."
3 . From the time
RTC was created in the early 80's until the time I left RTC which was
located at Gillman Hot Springs (hereinafter referred to as the "base"),
was at that time the most senior, most powerful and most influential organization
in all of Scientology. All at RTC were Sea Org members, as are all at
the base. But because of RTC's position, we were the elite at the base.
4. In March 1983, I became the Deputy Inspector General, External, and a member of the Board of Directors or RTC, as Treasurer. (The only other board members were Warren McShane as Secretary and Vicki Aznaran as President, during this time.) At the time I was appointed a member of the Board of Directors of RTC I was forced to sign an undated letter of resignation. This is standard practice with all Scientology board members and is another means by which the Scientology corporations are controlled while giving the appearance of corporate integrity.
5 . I have been privy to the destruction and alteration of documents to protect the group. On or about April of 1983 I was present at a meeting, which took place in Los Angeles, California at a Scientology office called Author Services, Inc. (ASI). ASI presented itself as the "literary agency" for Hubbard but it was actually the top of the Scientology empire at that time. All of Scientology was being directed from ASI in 1982. ASI was where various Scientology corporations went to receive orders.
6. Present at the
meeting was David Miscavige, then the chairman of the board of ASI, Vicki
Aznaran then the Deputy Inspector General of Religious Technology Center,
(RTC) and Lymon Spurlock, who was "Director of Client Affairs"
for ASI. Mr. Miscavige expressed concern at this meeting that there might
possibly be a raid on Scientology by the IRS. At this time, none of the
churches of Scientology had received tax exempt staturs. One principle
reason why tax exempt status had not been granted was the IRS's position
that Scientology's founder L. Ron Hubbard (LRH) was actually the managing
agent of Scientology in complete disregard of the corporate structure
of Scientology. We knew this to be a fact but also knew that it violated
IRS rules and thus had to be hidden.
7 . There was concern that the IRS would obtain the hundreds of daily, weekly and monthly LRH orders written by Mr. Hubbard and distributed throughout Scientology. These orders were commonly referred to in Scientology as "advices" to avoid the appearance that LRH was actually running Scientology. In fact, LRH was running Scientology. The principle concern expressed at this meeting was that the LRH orders or "advices" would be used to name L. Ron Hubbard as a managing agent of Scientology.
8. Because of an already existing fear that an LRH "advice" might fall in the wrong hands, these orders from him were written in a way that we could deny it was from him. His name was not on them. He was never cited in the dispatch except in the third person. There was no signature and a salutation in reply was never more than "Dear Sir." The routing at the top referred to him merely as "*." An asterisk. However if a person (or an agency) got enough of these, there was there would be little doubt that we were in touch with Hubbard (via ASI) and he was telling us and each corporation what to do to make him more money.
9. David Miscavige specifically stated that ASI was "already dealing with the problem", ridding ASI of any documents that would implicate L. Ron Hubbard as managing agent of Scientology. He stated that under his directive the LRH orders, or "advices", were being collected and transferred by truck to a Riverside County recycling plant where the documents were "pulped". This method of destruction was considered to be better then shredding. I was also given instructions that I was in charge of purging the remainder of the Scientology organizations of LRH orders. This was to include Church of Scientology of California (CSC); Church of Scientology International (CSI); and RTC.
10. Several weeks
after this first meeting I attended a second meeting at the ASI offices
concerning the continuing destruction of Scientology corporate documentation.
In attendance at the second meeting were David Miscavige, Lymon Spuriock,
Vicki Aznaran, Norman Starkey and Marty Rathburn. At this meeting, David
Miscavige for the first time stated that Scientology had been ordered
by a court to produce various documents concerning a former Scientology
member named Lawrence Wollersheim who had a lawsuit pending in Los Angeles
against the Church of Scientology of California. The court had ordered
Scientology to produce Mr. Wollersheim's entire "preclear" (PC)
11 . A " PC" file is one of several files kept on members. The PC file is the file that includes all written records of all "confessionals" done by the member. This means that it includes not only the most self-damaging material but it also reflects every problem the person might have had with the organization, including complaints. This PC file grows with the person's tenure in Scientology.
12. Mr. Wollersheim's PC file was several thousand pages in length.and stood as high as a six-foot tall man. Initially at this meeting it was decided that Mr. Wollersheim's PC file would be redacted and culled of any evidence or documentation which might assist Mr. Wollersheim in his lawsuit against CSC. There was also concern that the materials known as Clear, OT I, OT II, OT III and NED for OT's (NOTS) would be open to public inspection if Mr. Wollersheim's files were produced as ordered. Scientologists are taught that a person could catch pneumonia and die if that person is prematurely exposed to these "upper level" materials without first having taken many hours of preparatory auditing. Ultimately, approximately 50 pages were produced pursuant to the court order. Mr. Wollersheim's PC file was culled based on a direct order from David Miscavige.
13. Later, I was
informed that a second court order was issued to produce Mr. Wollersheim's
entire file. Faced with the prospect of having to produce the entire file,
David Miscavige gave orders that the entire file simply be destroyed by
14. Pursuant to Mr. Miscavige's orders I ordered Rick Aznaran to take Mr. Wollersheim's PC files to the recycling plant in Riverside to be pulped. Several hours after I gave the order to have Mr. Wollersheim's PC files destroyed, Mr. Aznaran returned and confirmed that the records had been pulped and even showed me a small bottle of pulped material, saying "Here's what's left."
15. The material that David Miscavige ordered destroyed and which Rick Aznaran had pulped was the same material that the court had ordered produced in Mr. Wollersheim's Los Angeles court case against CSC.
16. It is incumbent on this and every court, as well as the authorities, to realize the amount of deception, chicanery, lying, manipulation and outright criminality that Scientology will employ to hide the truth about their criminal activities. They will spend any amount of money to do this. I know because I was part of it for years. I received orders to break the law. I issued orders to break the law. I got others to break the law, and then I helped to hide these criminal activities just as they are hiding them now.
I declare under
penalty of perjury under the laws of the State of Colorado that the foregoing
is true and correct.
Executed this 21st day of June, 1999, at Boulder Colorado